New Recoupment Options

Date: February 21, 2012

The Centers for Medicare and Medicaid (CMS) recently issued new options for those facing recoupment of overpayments. Currently, when your local contractor has identified an overpayment, there is a delay of 40 days before they begin to recoup the overpayment from your EOBs.

Effective July 1, 2012, providers may elect recoupment to begin prior to the normal recoupment at day 41 after receipt of notice; interest is avoided if the overpayment is paid back in full before day 31.

The important points in MM7688 (Revised), issued January 27, 2012 are:

  1. To accelerate recoupment, you must notify the contractor in writing. This means via postal service, FedEx or other alternative carrier, e-mail, or by fax.
  2. You may elect a 1-time request for a specific demand letter or make it a permanent standing request.
  3. You can terminate the request in writing at anytime.
  4. Your written request must contain the following: Provider name and phone, Provider Medicare number and/or NPI, Provider or CFO signature, Demand letter number, Which option you are selecting (see link at bottom).
  5. Your request must be received by the contractor no later than the 16th day from the initial demand letter.
  6. When interest is assessed, it is done at simple interest of 10.50% according to 42 CFR 405.378, and begins on the 31st day. A hyperlink is provided here that contains the interest rate assessment particulars.
  7. It is considered a voluntary repayment.
  8. You are waiving certain rights to interest if the overpayment determination is overturned later. Follow the bottom link for information.

You can download CMS document MM7688 Revised by clicking on this link.

We believe providers should be aware of, but not necessarily elect this option without careful consideration. You are welcome to contact our office to discuss your options.

Recent News

Change to Processing for Telehealth Services Billed with POS 10

In calendar year (CY) 2024, the Centers for Medicare & Medicaid Services (CMS) issued a change to processing for telehealth services billed with POS 10. ...

Diabetes Cost Measure Misattributed to Ophthalmologists

The American Society of Cataract and Refractive Surgery (ASCRS), the American Society of Retina Specialists (ASRS) and the American Academy of Ophthalmology (AAO), met recently ...

Review Your 2022 MIPS Performance Feedback and Final Scores

The Centers for Medicare & Medicaid Services (CMS) has released the Merit-Based Incentive Payment System (MIPS) performance feedback and final scores for the 2022 performance ...

JZ Modifier Required July 1, 2023

The much-anticipated mandatory reporting of the JZ modifier for Part B Medicare begins July 1, 2023.  The new Medicare policy can be found here.  The ...

Cigna Hits the Brakes on Their New Modifier 25 Policy

Following fierce opposition from the physician community, the insurer Cigna announced today a delay in implementing a policy (PDF) that would have required submitting medical ...

Medical Consulting Group and Corcoran Consulting Group Announce Merger

Springfield, MO, April 27th, 2023. Medical Consulting Group (MCG), a provider of consulting services to ophthalmic practices and companies, and Corcoran Consulting Group (CCG), a ...

IHEEZO Gel gains Medicare Pass-Through

On March 13, 2023, Harrow® announced that the Centers for Medicare & Medicaid Services (CMS) has approved transitional pass-through reimbursement status for chloroprocaine hydrochloride ophthalmic ...

Cigna Change Modifier 25 Policy

As a result of a recent review, Cigna has announced it will require the submission of office notes with claims submitted for evaluation and management ...

Congress makes positive adjustments that affect ophthalmologists

In this Healio Video Perspective from Hawaiian Eye 2023, Kevin J. Corcoran, COE, CPC, CPMA, FNAO, discusses ophthalmic economic and regulatory updates for the year. ...

HHS Extends Covid-19 PHE

On Thursday, October 13, the U.S. Department of Health & Human Services (HHS) Secretary Xavier Becerra extended the nation's COVID-19 PHE for an additional 90 ...

Noridian Changes to Goniotomy LCD

Noridian has made changes to their Goniotomy coverage policy effective October 1st, 2022. It states: “Since there is no specific CPT® code for goniopuncture or ...

2021 MIPS Performance Feedback, 2021 MIPS Final Score, and 2023 MIPS Payment Adjustment Information

The Centers for Medicare & Medicare Services (CMS) has released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for the 2021 performance year, ...

Telehealth Place of Service Update

With a recent change to telehealth billing, billers need to be aware of an additional Place of Service code. What changed? Effective January 1, 2022, ...

Extension of Telehealth Flexibility

Last week, the U.S. House of Representatives approved legislation to further extend the Medicare telehealth flexibilities first instituted in response to the COVID-19 pandemic. If ...

AETNA No Longer Requiring Prior Authorization for Cataract Surgery

The American Society of Cataract and Refractive Surgery (ASCRS) and American Academy of Ophthalmology (AAO) have spearheaded a year-long effort to remove the policy that ...

2021 MIPS Final Score Preview Now Available

The Centers for Medicare & Medicaid Services (CMS) has opened the Final Score Preview period for the Merit-based Incentive Payment System (MIPS).  You can now ...

Guidance for Coding Goniotomy

Summary:   Two new ophthalmic surgical products have attracted interest from surgeons:  Streamline Viscoelastic Injector® (New World Medical) and IACCESS™ trabecular trephine (Glaukos).  In both cases, ...

CIGNA Changes Their Modifier 25 Policy

As a result of a recent review, CIGNA will require the submission of office notes with all claims submitted with evaluation and management (E/M) CPT ...

CMS Reweights Scoring for Cost Category for Groups in 2021 Quality Payment Program

The Centers for Medicare & Medicaid Services (CMS) announced on Monday, April 25th, that ALL eligible MIPS providers will automatically receive re-weighting of the Cost ...

IACCESS™ Trabecular Trephine – How to Code?

Summary:   Glaukos’ new product, the IACCESS™ trabecular trephine, raises interesting coding questions.  Standalone procedures should be reported on a claim for reimbursement as unlisted procedure, ...

Streamline® Viscoelastic Injector – How to Code?

Summary:   New World Medical’s new product, the Streamline® Viscoelastic Injector, raises interesting coding questions.  Standalone procedures with it should be reported on a claim for ...

HHS Extends the Public Health Emergency Waivers

On April 12, 2022, Secretary of Health and Human Services Xavier Becerra again renewed the public health emergency declaration that was initiated at the end ...

CMS re-opens MIPS Hardship Exception for Groups, Virtual Groups, and APM entities

The Centers for Medicare & Medicaid Services (CMS) announced March 3 that they re-opened the 2021 Extreme and Uncontrollable Circumstances (EUC) application for those submitting ...

HHS Extends the Public Health Emergency Waivers

On January 14, 2022, Secretary of Health and Human Services Xavier Becerra renewed the public health emergency declaration that was initiated at the end of ...